Air Quality and Noise

Opening statement: “Air quality would be affected by construction and operation of the project.” (4-192)\

The project would generate emission during construction due to gasoline and diesel-fired combustion equipment, as well as earth-moving activities (4-192)

The project would also generate ongoing emissions during operation, including emissions from: 2 new compressor stations in PA; “additional ancillary facilities” in PA; 2 new meter stations and 3 new regulator stations in PA (4-192)

PA’s climate: “Pennsylvania’s warmest temperatures are found in the southeast part of the state. During the summer, southeastern Pennsylvania can experience about 75% more days with high temperatures above 90  F, compared to the state average.” (4-193)

“States have the authority to adopt ambient air quality standards if they are more stringent than the NAAQS [National Ambient Air Quality Standards].” Pennsylvania (alone among those states affected by the ASP) has adopted pollution standards that go beyond those required by federal regulations, specifically: beryllium, fluorides, hydrogen sulfide, and settled particulate. (4-194)

“Areas where ambient air concentrations of the criteria pollutants are below levels listed in the NAAQS are considered attainment.” Areas where pollution exceeds federal standards are considered “nonattainment.” Lancaster County, PA, is designated a “nonattainment” region for exceeding federal air pollution standards. (4-194; chart 4-196)

“GHGs (green house gases) occur in the atmosphere both naturally and as a result of human activities, such as the burning of fossil fuels…The EPA found that the current and proposed concentrations of the six GHGs in the atmosphere threaten the public health and welfare of current and future generations through climate change.” (4-196). NOTE: The DEIS is an assessment of environmental impacts related to a massive fossil-fuel burning project—namely, the ASP. If the words above mean anything at all, how can FERC conclude, as it does, that the ASP would have “no significant” environmental impact?

Note: Despite the EPA’s dire warnings on Green House Gas emissions as noted above, “There are no NAAQS (National Ambient Air Quality Standards) or other significant thresholds for GHGs.” How absurd is that?

“Under PSD (Prevention of Significant Deterioration), any new major source modification of an existing source of air pollution is required to obtain an air quality permit before beginning construction…PSD also applies to an existing major source when physical modifications are made that result in increased emissions above the “major modification.” (4-197) NOTE: It appears that the DEIS considers only compressor stations, pipeline construction, and pipeline operations in its assessment of air quality impacts. Where does FERC assess the impacts associated with the increased natural gas extraction (fracking, injection wells, gathering line construction, etc.) from the construction of the ASP?

“Emissions of GHGs associated with the construction and operation of the [ASP], including all direct and indirect emission sources were calculated.” (4-201) Notes:

[1] FERC uses the passive voice here (“were calculated”). Who, in fact, conducted these calculations? Did Williams self report? Did Williams contract the agents responsible for these calculations? Or did FERC rely on a truly independent source?

[2] FERC claims that “all direct and indirect emission sources were calculated.” This implies that all reasonably projected, additional emissions to be generated by the ASP are included in this calculation—including increased fracking emissions; increased release of methane &amp; other pollutants due to increased extraction, shipping, and storage of this natural gas; projected emissions generated by shipping this product overseas to the markets for which its contracted; etc. Have these sources, in fact, been included in the calculations? If so, where is the data that was produced? If not, then “all direct and indirect emission sources” were not, in fact, “calculated.”

Note: This reviewer finds it deeply troubling that FERC repeatedly defers to Transco/Williams’ requests to adapt standard air quality studies in ways that would likely downplay project impacts. [1] When FERC “requested that Transco complete an air quality impact” analysis (4-120) [Aside: Why merely “requested,” rather than “mandated”? Who’s in charge here, FERC?], Transco, in turn, “indicated its preference” to produce monitoring data of its own, rather than relying on the EPA’s AERSCREEN or AERMOD results, for fear that these tools “may overestimate impacts associated with certain pollutants.” FERC permitted Transco to make such adjustments. (4-210) Question: Which independent body reviewed and approved the air quality monitoring plan used by Transco in order to circumvent reliance on the EPA’s standard monitoring tools? Note: FERC’s requirements, as outlined above, carried with them a requirement that Transco provide air quality monitoring data for 1 year. “To date,” however, “Transco provided…about 6 months of air quality monitoring…” QUESTION: Why is this DEIS being released only halfway through the required reporting period?

It appears that Transco was permitted to choose when they would—and would not—gather air quality monitoring data at a compressor station, in an attempt to selectively produce results more amenable to their purposes. For example, in order to avoid documenting air pollution associated with their own construction activities at Compressor Station 517, they were allowed to suspend monitoring—apparently until a more fitting time of their own choosing. (4-210)

“…we reviewed the air quality monitoring data collected by Transco…” (4-213). Question: Why isn’t an independent party required to submit this data? After all, Transco has strong motivation for underreporting pollution levels. Who is holding them accountable for the data being supplied to FERC?

“While this analysis shows that the proposed modifications to Compressor Stations 517 and 520 would not result in significant impacts on air quality, Compressor Stations 517 and 520 were not operating at the full station loads during air quality monitoring. Therefore, the potential exists for higher impacts from existing sources when Compressor Stations 517 and 520 are operating at full load. Additionally, the modeled impacts for Compressor Station 190 did not include existing sources because Compressor Station 190 was not running during the time of monitoring. Therefore, a similar analysis can not be completed for Compressor Station 190. While the EPA’s background ambient air quality data used in the modeling analysis was collected when Compressor Station 190 was operating, the EPA’s air monitoring station is located approximately 15 miles from Compressor Station 190, and the potential exists for higher localized impacts in proximity to the station.” (4-213/4)

NOTE: Once again, flatly insufficient/incomplete data renders FERC’s assessment of ASP’s environmental impact premature. Since FERC is “requesting” that Transco submits the requisite data “prior to the issuance of the final EIS,” we can only ask: why didn’t FERC wait for this critical information before issuing the draft EIS? Furthermore, have provisions been made to ensure that Transco, at some point, submits air quality data based on full station loads? If, under those conditions, FERC determines that proposed modifications would push air pollution levels beyond acceptable levels, will FERC retroactively disapprove the project and/or halt construction? Honestly.

“We received comments about the potential exposure to released radon gas. The downstream use of natural gas in the market areas, including the effects of burning gas and exposure to radon in homes, is beyond the scope of this EIS.” (4-218) Question: If FERC does not assess and regulate the downstream impacts of the very project for which they are giving approval, whose responsibility is that?

The EPA has issued guidelines for noise standards set at 55 bDA by day, and 45 dBA by night (= max level of 48.6 dBA on a 24-hr basis)(see top 4-220). However, an acoustical analysis conducted at Transco’s Compressor Station 520 demonstrated that noise levels far exceed these EPA standards at 5 NSAs, with noise levels ranging “from 59.7 to 65.0 dBA. (4-221) Question: Why are these violations premitted to happen? And why, given these flagrant violations, is FERC still willing to issue preliminary approval for the ASP per this DEIS? Furthermore, this reviewer is troubled by the apparent disregard demonstrated by FERC toward rural communities, insofar as the DEIS refers to this non-compliant compressor station as being situated in a “primarily rural” area with “a few scattered residences.” Presumably, this is why FERC offers no explanation for why these violations are ongoing, nor is any remedy proposed. After all, it’s just “a few scattered residences” that are affected. (4-221)

“The results of the noise assessments indicate that the estimated noise attributable to HDD (Horizontal Directional Drilling) equipment operations would increase above FERC’s noise level criterion of 55 dBA L dn at three NSAs if no additional litigation is employed…Moreover, the noise of the HDDs would exceed 55 dBA L dn (FERC threshold) at NSAs at the following HDD entry and/or exit locations…” (4-233) Furthermore Transco “indicated” that property owners would be notified of planned nighttime construction activities.” The DEIS claims: “Since mitigated noise levels attributable to HDDs are anticipated to be below the FERC sound criterion at any NSAs, overnight construction, if necessary, is not expected to create significant impacts on surrounding NSAs. However, if the noise levels cannot be reduced to target levels, Transco has committed to providing temporary housing or equivalent monetary compensation to the occupants of affected NSAs in the project area until the construction activities are completed” (4-234)—NOTE: “HDD activities at the three sites are estimated to be completed over a 3- to 6-month period.” (4-229) Italics added by reviewer to highlight the highly subjective language employed in FERC’s handling of this section. NOTE: Displacing unwilling residents from their homes during construction is an extraordinary exercise of coercive power. A lot of questions are also left unanswered: Do these landowners know that they may legally be driven from their homes, for up to half a year, due to intolerable noise levels during construction? Who determines whether night construction is “necessary”? Is Transco committing to providing alternate housing the same thing as Transco being legally bound to do so? Who determines the point at which a non-significant impact becomes “significant”?

Regarding construction activities including “grading, clearing, grubbing, and trenching operations”—“if the noise levels cannot be reduced to target levels, Transco has committed to providing temporary housing or equivalent monetary compensation to the occupants of affected NSA (Noise Sensitive Areas) in the project area until the construction activities are complete.” (4-235)

“Blasting would be required during construction in some areas with shallow depth to bedrock (i.e. less than 8 feet).” (4-235)